Lawrence Lokken (Florida), Dividend Equivalents: 

Foreign investors are generally subject to a 30 percent tax on dividends received from U.S. companies. Through various derivative instruments and transactions, an investor can achieve the financial equivalent of an investment in a U.S. stock, without actually owning the stock. The U.S. Congress decided in 2010 that an investor receiving a "dividend equivalent" through such a derivative investment should be taxed on this receipt as though it actually were a dividend. Implementation of this decision has proven to be difficult. 

After several iterations of regulations under the relevant statutory provisions, the Treasury and the IRS have most recently announced that the regulations will become fully effective in the year 2027. This article explaining the regulations is a draft of materials to be included in the treatise, Boris I. Bittker & Lawrence Lokken, Federal Taxation of Income, Estates, and Gifts.

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